A health and safety representative represents employees in workplace health and safety matters, while a safety officer generally assists the employer with managing and implementing its occupational health and safety system. Although their duties may overlap, they are different roles with different purposes, appointment arrangements and lines of responsibility.

A safety representative is specifically recognised under the Occupational Health and Safety Act. A safety officer, by contrast, is generally appointed by the employer as a competent safety practitioner to help administer workplace compliance. The mere appointment of a safety officer does not replace the need for employee safety representatives where the legal threshold applies.

Why are these roles so often confused?

The terms are frequently used as though they mean the same thing. This normally happens because both people may conduct inspections, identify hazards, attend safety meetings and participate in incident investigations.

The important distinction is not only what they do. It is also:

• Who they represent;
• Why they are appointed;
• How they are selected;
• What authority they have;
• Who they report to; and
• Whether the appointment is specifically required by legislation.

A safety representative gives employees a formal voice in workplace health and safety. A safety officer helps the employer organise, administer and monitor the safety system.

What is a health and safety representative?

A health and safety representative, often called a safety representative or SHE representative, is a full-time employee designated in terms of Section 17 of the Occupational Health and Safety Act.

Employers with more than 20 employees at a workplace must generally designate health and safety representatives for that workplace or for sections of it.

The minimum ratio is ordinarily:

• Shops and offices: One representative for every 100 employees, or part thereof.
• Other workplaces: One representative for every 50 employees, or part thereof.

The representative must be familiar with the conditions and activities in the part of the workplace for which he or she is designated.

For a full explanation of the calculation, read How Many Health and Safety Representatives Does Your Company Need?

Who does the safety representative represent?

The health and safety representative represents employees in health and safety matters. The role is intended to give workers a structured way to raise hazards, complaints and recommendations with the employer.

The representative does not become part of management simply because he or she has received an appointment letter. The person remains an employee representative when performing the functions provided for by the Act.

This is why employee consultation is important when representatives are nominated, elected and designated.

What are the functions of a safety representative?

Section 18 of the Occupational Health and Safety Act gives health and safety representatives several functions. These may include:

• Reviewing the effectiveness of workplace health and safety measures;
• Identifying potential hazards and dangerous incidents;
• Examining the causes of workplace incidents with the employer;
• Investigating employee health and safety complaints;
• Making recommendations to the employer;
• Inspecting the workplace, machinery, equipment and protective equipment;
• Participating in consultations with inspectors;
• Accompanying an inspector during a workplace inspection;
• Receiving relevant health and safety information; and
• Attending health and safety committee meetings.

These functions should be performed during normal working hours, and the employer must provide the assistance, facilities and training that the representative may reasonably require.

What is a safety officer?

A safety officer is generally a person appointed by the employer to assist with the practical implementation, monitoring and administration of occupational health and safety requirements.

Depending on the workplace, the role may also be called:

• Health and safety officer;
• OHS officer;
• SHE officer;
• Safety practitioner;
• Construction health and safety officer; or
• Safety coordinator.

The exact title is less important than the person’s competence, written responsibilities and the work they are expected to perform.

A safety officer may be:

• A permanent employee;
• A full-time safety practitioner;
• A part-time employee with defined OHS responsibilities;
• An external consultant;
• An outsourced contract safety officer; or
• A project-specific construction safety officer.

Is every company legally required to appoint a safety officer?

There is no general provision in the Occupational Health and Safety Act stating that every employer must appoint someone with the job title “safety officer”.

The employer must nevertheless provide and maintain, as far as reasonably practicable, a working environment that is safe and without risk to employees. The employer must therefore ensure that competent people are available to perform the safety work required by the business.

A formal safety officer may be necessary because of:

• The size of the workforce;
• The risks associated with the operations;
• The complexity of the safety-management system;
• Construction-project requirements;
• Client or principal-contractor specifications;
• Contractual requirements;
• Industry standards;
• Multiple branches or shifts; or
• The volume of inspections, records and corrective actions that must be managed.

What does a safety officer normally do?

The safety officer’s duties depend on the workplace and written appointment. Typical responsibilities may include:

• Helping management implement the OHS policy and safety system;
• Conducting workplace inspections and compliance audits;
• Assisting with hazard identification and risk assessments;
• Maintaining safety files, registers and legal appointments;
• Monitoring corrective actions;
• Reviewing contractor safety documentation;
• Coordinating inductions and toolbox talks;
• Monitoring training and medical fitness records;
• Participating in incident investigations;
• Preparing safety reports for management;
• Attending health and safety committee meetings;
• Monitoring the condition and use of personal protective equipment;
• Assisting with emergency planning and drills; and
• Advising management on identified areas of non-compliance.

You can also read Altra Medical Productions’ existing guide, The Role of a Safety Officer Explained.

Safety representative vs safety officer: the main differences

Can one person perform both roles?

In some workplaces, the same employee may be referred to as both a safety representative and a safety officer. This arrangement should be approached carefully.

The roles have different purposes. A person acting as a safety representative must be able to represent employees, raise complaints and make recommendations to the employer. A person acting as a safety officer may be expected to monitor employees, enforce company procedures and report directly to management.

Combining the roles can create a conflict where the employee is expected to represent workers while simultaneously acting as management’s compliance monitor.

Before combining the roles, the employer should consider:

• Whether employees have genuinely participated in selecting the representative;
• Whether the person can independently raise employee concerns;
• Whether management duties will conflict with employee representation;
• Whether the person has enough time to perform both functions;
• Whether the appointment meets client or regulatory requirements; and
• Whether the person has the competence required for each role.

Can a manager be the safety representative?

A manager may be a full-time employee familiar with the workplace, but that does not automatically make the appointment appropriate.

The purpose of the safety representative role is to represent employees. A senior manager who hires, disciplines and evaluates employees may struggle to provide independent employee representation.

The appointment must also follow the consultation and nomination or election arrangements agreed between the employer and employees. Management should not simply select a manager and label that person the employee representative.

Can the safety officer appoint or control the safety representative?

A safety officer may help coordinate the nomination, election, appointment, training and meeting process, but the safety officer should not personally select the employee representative without proper consultation.

The employer remains responsible for ensuring that the legal process is followed.

The safety officer may work closely with representatives by:

• Providing inspection checklists;
• Helping schedule workplace inspections;
• Recording hazards and recommendations;
• Tracking corrective actions;
• Arranging committee meetings;
• Providing access to relevant safety information; and
• Assisting management to respond to recommendations.

Does appointing a safety officer remove management’s liability?

No. The employer’s general duties under the Occupational Health and Safety Act remain with the employer.

A safety officer can provide professional advice, coordinate compliance activities and alert management to problems. However, the safety officer cannot always approve budgets, stop production, employ additional personnel or authorise major corrective work.

Management must:

• Provide adequate resources;
• Act on identified hazards;
• Implement reasonably practicable controls;
• Provide suitable information, instruction, training and supervision;
• Ensure that appointments are supported with real authority; and
• Monitor whether the safety system is effective.

Does appointing safety representatives remove management’s liability?

No. Health and safety representatives participate in the safety process, but they do not take over the employer’s duty to provide and maintain a safe workplace.

A representative may identify a damaged guard, blocked emergency exit or unsafe procedure. It remains the employer’s responsibility to investigate the issue and implement appropriate corrective action.

Representatives should not be blamed for management’s failure to act on hazards they reported.

Does a workplace need both a safety representative and a safety officer?

Many workplaces benefit from having both.

A company may need safety representatives because its employee numbers exceed the Section 17 threshold. It may also need a safety officer because the operation is large, high-risk, administratively complex or subject to construction or client requirements.

Example: a manufacturing plant

A manufacturing plant with 140 employees would ordinarily require at least three health and safety representatives under the one-per-50 ratio.

The plant may also appoint a full-time safety officer to:

• Maintain the safety-management system;
• Coordinate inspections and risk assessments;
• Track training and medical records;
• Manage contractor compliance;
• Assist with incident investigations; and
• Report unresolved risks to management.

The representatives and safety officer can work together, but the safety officer does not replace the three employee representatives.

Example: a small office

An office with 18 employees does not ordinarily cross the Section 17 numerical threshold for compulsory safety representatives.

The employer still has health and safety duties and may voluntarily appoint and train a representative. The company may also use an external OHS consultant to conduct periodic inspections, maintain its safety system and advise management.

What qualifications or training do the roles need?

Safety representative training

The employer must provide the training that the health and safety representative may reasonably require to perform the role.

Effective training should cover:

• The employer’s and employees’ legal duties;
• The functions of health and safety representatives;
• Workplace inspection methods;
• Hazard identification;
• Incident participation;
• Employee complaints and recommendations;
• Health and safety committees; and
• Inspection and meeting records.

Altra Medical Productions offers a two-day Safety Representative Training programme covering statutory requirements, inspections and participation in workplace safety structures.

Safety officer competence

The competence required of a safety officer depends on the work the person will perform. A person managing a low-risk office system may require a different level of competence from someone responsible for a major construction project, factory or high-risk industrial site.

The employer should consider the person’s:

• Formal education and training;
• Knowledge of applicable legislation;
• Industry experience;
• Understanding of the workplace hazards;
• Risk-assessment competence;
• Incident-investigation competence;
• Ability to conduct audits and inspections;
• Knowledge of contractor management; and
• Any registration required for the specific project or appointment.

Common mistakes employers make

1. Appointing a safety officer instead of employee representatives

A safety officer does not replace the representatives required under Section 17 when the workplace exceeds the applicable employee threshold.

2. Calling the safety representative the safety officer

Using the wrong title creates confusion about who the person represents and what authority the appointment provides.

3. Expecting the representative to manage the full OHS system

A representative may identify hazards and make recommendations, but should not automatically be made responsible for all files, risk assessments, training records, contractor controls and legal compliance.

4. Giving the safety officer responsibility without authority

A safety officer cannot correct serious problems without management support, resources and access to decision-makers.

5. Treating the appointments as a transfer of liability

Neither appointment removes the employer’s obligation to provide a safe and healthy workplace.

6. Failing to train the representative

An appointment letter alone does not give the person the knowledge needed to inspect the workplace and participate effectively.

7. Using an external consultant as the employee representative

An external consultant may perform safety-officer or advisory services, but generally cannot replace the full-time employee who must serve as the workplace health and safety representative.

Which role does your workplace need?

Safety appointment checklist

• Confirm the number of employees at each workplace.
• Determine how many health and safety representatives are required.
• Consult employees on the representative-selection process.
• Define the workplace or section represented by each person.
• Issue written designations.
• Provide appropriate representative training.
• Establish a health and safety committee where required.
• Assess whether the company needs dedicated safety-officer support.
• Define the safety officer’s duties, authority and reporting line.
• Confirm whether project-specific registration or competence is required.
• Provide enough time, resources and management support.
• Review whether the appointments are functioning in practice.

Frequently asked questions

Is a SHE representative the same as a safety representative?

Yes. SHE representative, OHS representative and health and safety representative are commonly used to describe the employee representative designated under the Occupational Health and Safety Act.

Is a SHE representative the same as a safety officer?

No. The SHE representative represents employees in workplace safety matters. The safety officer generally assists the employer with implementing and administering the safety system.

Can a safety officer be outsourced?

Yes, safety-officer and OHS consulting services can often be outsourced, provided the arrangement is suitable for the workplace and meets any applicable legal, project, client and competence requirements.

Can a safety representative be outsourced?

Generally not. A health and safety representative must ordinarily be a full-time employee who is familiar with the conditions and activities in the workplace or section being represented.

Can the safety officer chair the health and safety committee?

The committee’s arrangements should be agreed and properly documented. A safety officer may support or facilitate the committee, but the committee must remain properly constituted and employee representatives must be able to participate meaningfully.

Can the safety officer investigate incidents?

Yes, where the person has been assigned that duty and is competent to perform it. Safety representatives may also participate in examining incident causes and related recommendations.

Who is responsible if the safety officer reports a hazard and management does nothing?

Management cannot avoid responsibility by blaming the safety officer after failing to act on a properly reported hazard. The employer remains responsible for assessing the risk and implementing reasonably practicable controls.

Does a small business need a safety officer?

Not every small business is legally required to employ a full-time safety officer. The decision should be based on the hazards, applicable regulations, client requirements and the amount of work needed to maintain compliance.

This article provides general information on South African occupational health and safety requirements. Specific appointments should be assessed against the applicable legislation, regulations, workplace risks, client specifications and project requirements.